Minister of Finance Regulation Number 44 of 2026 Introduces New Rules on Tax Representatives: Family Members May Now Be Appointed as Representatives

Introduction

On 20 June 2026, the Ministry of Finance issued Minister of Finance Regulation Number 44 of 2026 on Requirements and Procedures for the Appointment of Tax Representatives (“MOF Regulation 44/2026”), which took effect on 6 July 2026.

MOF Regulation 44/2026 establishes a new legal framework governing the appointment of tax representatives to exercise taxpayers’ rights and fulfill their tax obligations. The Regulation broadens the categories of parties eligible to act as tax representatives, clarifies competency requirements, and introduces more comprehensive administrative procedures for granting, amending, and terminating powers of attorney.

MOF Regulation 44/2026 revokes and replaces Minister of Finance Regulation Number 229/PMK.03/2014 on Requirements and Procedures for the Appointment of Tax Representatives (“MOF Regulation 229/2014”), which was considered no longer aligned with developments in the tax administration system and the need for greater legal certainty.

Comparison

The following table compares MOF Regulation 44/2026 with MOF Regulation 229/2014:

Key Provisions

Eligible Tax Representatives

Under Article 2, a taxpayer may appoint a tax representative from among the following parties:

·      a tax consultant;

·      another qualified party meeting the applicable competency requirements; or

·      a family member.

The inclusion of family members constitutes one of the principal changes introduced by MOF Regulation 44/2026, providing taxpayers with greater flexibility in appointing representatives to exercise their tax rights and fulfill their tax obligations.

Competency Requirements

MOF Regulation 44/2026 establishes competency requirements that vary according to the category of tax representative.

Tax consultants must satisfy the applicable professional licensing requirements.

Other qualified parties must satisfy the competency requirements prescribed by the Regulation.

Family members acting as tax representatives are required to submit a statement letter confirming their family relationship with the taxpayer and fulfill the applicable administrative requirements.

Special Power of Attorney

The appointment of a tax representative must be evidenced by a Special Power of Attorney (Surat Kuasa Khusus).

The Special Power of Attorney must contain at least:

·      the identity of the taxpayer;

·      the identity of the tax representative;

·      the scope of authority granted;

·      the tax rights and obligations covered by the authorization; and

·      the signatures of both the taxpayer and the appointed representative.

MOF Regulation 44/2026 also regulates procedures governing the amendment, revocation, and termination of a Special Power of Attorney.

Standardized Administrative Formats

To facilitate administrative standardization, MOF Regulation 44/2026 provides official document templates in its Annex.

These standardized templates include:

·      Special Power of Attorney;

·      Statement Letter (for family members);

·      Revocation of Special Power of Attorney;

·      Notification of the Termination of the Grant of Authority; and

·      Letter of Appointment issued by a tax representative.

Transitional Provisions

Pursuant to Article 15, Special Powers of Attorney granted by taxpayers and submitted to the Director General of Taxes before the entry into force of MOF Regulation 44/2026 remain legally valid and may continue to be used to exercise tax rights and fulfill tax obligations in accordance with their respective terms.

Furthermore, Article 16 establishes a transitional period for parties other than tax consultants who previously satisfied the competency requirements under the former regulatory regime by holding either:

·      a tax brevet certificate; or

·      at least a Diploma III degree in taxation from a university accredited with an A rating.

Such parties may continue to be appointed as tax representatives only until 31 December 2026.

To rely on this transitional provision, the taxpayer must prepare a physical Special Power of Attorney, attach a copy of the relevant tax brevet certificate or diploma, and submit the documents directly to the Tax Service Office (Kantor Pelayanan Pajak – “KPP”) for administration within the information system of the Directorate General of Taxes (Direktorat Jenderal Pajak – “DJP”).

Closing

MOF Regulation 44/2026 expands the categories of persons who may be appointed as tax representatives, clarifies competency requirements, and strengthens the procedures governing the exercise of taxpayers’ rights and the fulfillment of their tax obligations through appointed representatives. The Regulation also introduces clearer rules governing the issuance and administration of Special Powers of Attorney and establishes transitional provisions for parties that qualified under the previous regulatory framework.

With the entry into force of MOF Regulation 44/2026, taxpayers and all appointed representatives—including tax consultants, other qualified parties, and family members—must ensure that every appointment complies with the applicable administrative and competency requirements prescribed by the Regulation. Since MOF Regulation 229/2014 has been revoked and declared no longer in effect, all appointments of tax representatives from 6 July 2026 onward must comply with MOF Regulation 44/2026, including the transitional provisions that remain available only until 31 December 2026 for parties relying on the previous qualification requirements.